Many financial institutions such as mutual funds, for example, are subject to a variety of requirements arising from procedural and operational aspects of conducting business. These requirements may arise from rules, regulations or laws at the local, state, or federal level, and it is typically necessary for financial institutions to evaluate and promote compliance with such requirements.
For example, Section 312 of the USA Patriot Act requires United States financial institutions to establish and implement compliance programs that address money laundering risks perceived by the United States Department of the Treasury with respect to “foreign correspondent accounts” established or maintained by foreign financial institutions. Section 312 requires financial institutions to incorporate due diligence programs into their anti-money laundering programs which are reasonably designed to identify accounts opened or maintained for a foreign financial institution and to monitor such accounts to detect and report known or suspected money laundering activity. Among other entities, the Treasury Department defines foreign financial institutions to include: foreign banks, foreign mutual funds and foreign offices of United States covered institutions; non-U.S. entities that if located in the United States would be required to register as securities broker/dealers; futures commission merchants or mutual funds; and readily identifiable foreign currency dealers and foreign money transmitters.
What are needed are more effective and efficient tools, techniques and processes for collecting, analyzing and managing data needed by financial institutions to promote compliance with federal laws and regulations, such as the USA Patriot Act.